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Air Force Proposal to Close Public Lands Lacks Justification

The Air Force this month released the draft environmental impact statement (EIS) for its proposal to take control of hundreds of square miles of public lands to expand training activities at its Nellis Test and Training Range (NTTR) in Nevada, although the report does not adequately explain why alternatives that require less impacts on public lands were abandoned. The proposal would shut down a significant portion of the Desert National Wildlife Refuge, remove protections from key wildlife habitat, and call for building 115 miles of new fence that would block wildlife movement. The document portrays these steps as the only viable path forward to accommodate expanded training and testing scenarios, but leaves significant gaps in its review of alternatives.

A golden eagle faces off with a bighorn sheep at a watering hole in the Desert National Wildlife Refuge. Photo: USFWS

Three Primary Activities: Emitters, Bombing, and Irregular Warfare

To understand why the Air Force needs more land - and to identify alternatives to shutting down portions of the Desert National Wildlife Refuge - we can take a look at the purpose and need statement in the recently released EIS. The underlying problem the Air Force faces is a traffic jam. The Nellis Test and Training Range is operated by the Air Force, but it
is a very popular place for the entire Department of Defense to prepare
personnel for combat and also develop new weapons. Although the NTTR already
spans 4,608 square miles, the Air Force believes it needs access to more land to increase the number of testing and training missions. That boils down to three activities that the Air Force says require it to expand control over a vast swath of the wildlife refuge and shut down public access to desert wildlands:

An example of threat emitter. The need for these is vanishing
with newer generation aircraft.

Emitters: In order to train aircrews, the Air Force needs to simulate ground-based threats, like surface-to-air missiles. This can be accomplished by mobile platforms that emit signals. The signals are picked up by the aircraft and interpreted as a threat, and give the aircrew an opportunity to take defensive actions. In order to deploy these emitters on the ground, the Air Force wants "ready access" to more roads in the wildlife refuge. Nowhere in the document does the Air Force analyze the potential to use on board threat simulators that are being built into newer generation aircraft and require no ground disturbance.

Bombing: The Air Force's proposal would not expand impact areas - swaths of land where live munitions are used - although it may exercise the option to do so in the future. However, the Air Force states that newer generation aircraft will launch munitions from higher altitudes against the targets in the existing impact areas. This means that the safety zone around impact areas will need to be increased just in case a bomb or missile goes astray. The Air Force proposal focuses on an impact area closest to open public lands, but does not adequately explain why it could not use any of the other impact areas across the NTTR that are further from open public lands and would not require closing down additional lands.

A screenshot from a YouTube video shows the mock city at NTTR.

Irregular Warfare: Within the impact zone closest to the open public lands is a mock city. It consists of standard metal shipping containers stacked and arranged to simulate buildings and military facilities among a network of dirt roads. The Air Force does not use these buildings for bombing practice. Instead, they provide a place for ground forces to train in irregular warfare - stealthy missions performed by small teams to go after specific targets. The Air Force's proposal explains that it needs expanded access to wildlife refuge lands so that it can land aircraft on a to-be-constructed dirt airstrip, and disembark these small teams of special forces who will hike several miles to the mock city for training scenarios. However, the Air Force acknowledges that it could accommodate this airstrip in existing NTTR lands. The Air Force also does not explain why it could not make use of lands in the northern portion of NTTR to support such irregular warfare training.Does the Proposal Justify Closing the Wildlife Refuge for These Activities?

I don't think so. Let's take this step by step.General Patton Meets the Information Age: The Air Force can always make the case that access to more land and more air space will give it an opportunity to provide its personnel with more realistic training. General Patton made this case as he prepared US troops for World War II. Patton's troops and tanks utilized nearly 18,000 square miles of the desert to prepare US personnel for battle against the Nazis in North Africa. That was in 1942.

General Patton's troops train in the Mojave Desert during World War II. Photo from the General Patton Memorial Museum.

What the Air Force needs is not a vast landscape for ground troops to battle over, but for pilots roaming the air space above to detect and react to threats as they approach a target on the ground. The Air Force's own proposal states that it does not need more ground targets or impact areas. They need places to deploy threat emitters. But newer generation aircraft actually come with computers that aid training scenarios. The aircraft computer can be programmed to simulate a vast array of ground-based and aerial threats to which the pilot can react. So the Air Force can either spend millions of dollars purchasing, deploying and maintaining physical threat emitters on the ground, or it can program an aircraft's computer to deliver the same experience to the pilot without a need for any physical assets on the ground at all.

It's known as "live, virtual, constructive" training, but it's not
mentioned anywhere in the Air Force's proposal as an alternative to
shutting down public lands. It's almost like the popular phone app "Pokemon Go," but a lot more sophisticated. The F-35 - one of the Air Force's newest aircraft - has this capability built in and we taxpayers are collectively spending billions of dollars to buy it for our aircrews. The F-22 - another advanced fighter that trains at NTTR - is receiving the capability, and older aircraft can be modified to carry this capability. (For more on this alternative, see here, here, here [PDF], and here [PDF].)

Even though the Air Force proposal does not discuss the "live, virtual, constructive" alternative, let's assume there is at least some valid reason for the Air Force to station physical threat emitters on the ground. The Air Force says that it needs a one mile buffer around the emitters, which are mobile. The Air Force says it also prefers to move these emitters around to provide aircrew with dynamic training opportunities (we all know that if a teacher doesn't change an exam's questions once in a while you have a problem). But the Air Force proposal does not identify specific roads and sites for threat emitters. It just says it wants access to hundreds of square miles of land for an activity that should only impact a handful of acres of land. The Air Force should identify priority roads and sites for threat emitters and reduce the impact on public land access. Since emitters do not have to be permanent, fixed facilities, the impact on public lands should not be permanent either. Combined with our taxpayer-funded gift of super-advanced aircraft that can simulate their own threat environment, it seems reasonable for us to expect some more precision in the Air Force's proposal."Shift Cold"- Bombing Runs Without Closing Public Access: When an aircraft is about to drop a laser guided bomb on a military facility and a civilian appears to enter the target zone, the crew can "shift cold." That means move the laser designator to an area nearby so that the bomb falling toward the initial target changes course and detonates further from the civilian. The Air Force does not want to harm civilians during its training scenarios. But we want the Air Force to "shift cold" so that its efforts to enhance training do not harm the public's access to the Desert National Wildlife Refuge. Ensuring public safety is one reason the Air Force is advocating for the closure of a large portion og the wildlife refuge. There is a designated impact area in the NTTR that is adjacent to open wildlife refuge lands. At the moment, the Air Force probably mostly uses that impact area to train low-flying attack jets. The jets are dropping their bombs from very low altitudes, so even if a bomb or rocket goes astray, it wont make it over the mountains and endanger the public.

A target is destroyed in Range 62A in the NTTR. The mountains in the background separate this impact area from the open public lands beyond.

But the Air Force is slowly replacing those low-flying attack jets that first flew in 1972 (old, but sturdy!) with more advanced aircraft like the F-35. The F-35 flies higher and faster, but has advanced sensors that still allow it to target small enemy vehicles below. Imagine that you are driving your Jeep on Alamo Road in the Desert National Wildlife Refuge. Far overhead is an F-35 flying toward the impact area in the NTTR, just a dozen or so miles to the west of you. This impact area is known as Range 62A. The F-35 drops a laser guided bomb against Range 62A. In most instances that bomb will hit the target in that portion of NTTR that is closed to the public. But there could be a worst case scenario where something goes wrong and the bomb falls directly onto the wildlife refuge lands where you are enjoying your well-deserved weekend drive on backcountry desert roads. This is one of the reasons the Air Force gives for wanting to close Alamo Road.

Whether or not the Alamo Road area of the Desert National Wildlife Refuge (in the green shaded area on the right, labeled "Alamo Expansion") is closed to the public may hinge on whether the Air Force wants to close public lands or focus its training efforts on an impact area closer to the Nevada National Security Site (outlined in purple and already closed to the public).

But the Range 62A impact area right next to the wildlife refuge is not the only impact area in the NTTR. It is one of many. In fact, there is another impact area further to the west known as Range 64A. The Air Force proposal says that it cannot use this range because of unspecified conflicts with the National Nuclear Security Administration's (NNSA) facilities in a vast area known as the Nevada National Security Site. Herein lies the problem with the Air Force proposal. The NNSA facility is further from Range 64A than Alamo Road is to Range 62A. In fact, the NNSA facilities appear to be beyond the weapon safety footprint for Range 64A. So the rationale for eliminating use of Range 64A as an alternative to closing more public lands is unclear. Based on the information provided in the proposal, the Air Force favors closing hundreds of square miles of public lands so that it can use Range 62A instead of accepting a probably marginal cost for using Range 64A. Maybe an aircraft could not approach a target in Range 64A from directly over the NNSA facility, so the approach would be limited to 340 degrees instead of 360 degrees. Can the Air Force live with a 340 degrees approach for this specific impact area in exchange for us being allowed continued access to our public lands?

The horizontal black lines labeled "Range 62A" and "Range 64A" depict
the same distance from existing designated impact areas in NTTR. Range 62A is
much closer to the Desert National Wildlife Refuge (Alamo Road) than
Range 64A is to the NNSA facility, which is to the west of the blue and
black border and green shaded area. The safety footprint for Range 64A would be within NTTR's existing area, although the approach may be limited to slightly less than 360 degrees.

Shipping Containers and Dirt Airstrips are Cheap: Accommodating the Air Force's irregular warfare training requirements should not necessitate the closure of wildlife refuge lands. The mock city that the Air Force built near the open public lands is made up of shipping containers, as I described above, and surrounded on most sides by sufficient terrain already closed to the public and capable of hosting a dirt airstrip from which special forces can approach the mock city. In fact, the Air Force's proposal already identifies two other potential landing points for the special forces within the existing NTTR boundary. Accommodating these new landing points may require changes to how those lands are managed, but it would not require the same closures for an insertion point in lands currently open to the public.

The Air Force's own proposal shows that it could accommodate irregular warfare insertion points (the upside down red triangles) within the existing NTTR boundaries (yellow border) without closing public lands. Two of the three options are within existing NTTR lands.

Let's say hypothetically that the Air Force suddenly decides that its two insertion points within NTTR are no longer viable. That it must construct a dirt airstrip near Alamo Road so that special forces can hike over a dozen miles to the mock city it built near Range 62A. This area, after all, is close to its unmanned aerial systems (i.e. drones) base at Creech Air Force Base, a small airstrip near Indian Springs along US Route 95 (yes, there are multiple airfields surrounding the vast NTTR). And pairing drones with special forces operations is now a part of its warfare doctrine. Cant we build a mock city on some other stretch of the NTTR or another training range at relatively minimal cost? Yes. The Air Force's NTTR contains another "shipping container" city in the North Range that happens to be near an area that the Air Force plans to use for drone training in Range 77. And relocating or modifying these irregular warfare training areas is not prohibitive. Each shipping container may cost $1,500 to $5,000 each (well within the Department of Defense's budget rounding error). The Air Force could modify the shipping container cities in northern portion of the NTTR in a cost effective manner and accommodate irregular warfare training there without closing public lands in the wildlife refuge.

Leave the Refuge Alone

There are ways to accommodate the Air Force's training needs without shutting down public access to more of the wildlife refuge. The Air Force's proposal does not adequately explore these avenues. The NTTR already encompasses 4,608 square miles. And the military already controls more than 21,000 square miles of land in the southwestern US. There is indeed some wiggle room in the Air Force's proposal, even if the text does not illuminate the alternatives.

I don't think this is an either/or scenario. We can give the best training and equipment to a lieutenant flying thirty thousand feet overhead in an F-35 without having to tell our children about places in the US that we used to have the freedom to explore before their time. Let's make this work.

The public may submit comments on the Air Force's proposal until March 8, 2018. Follow this link to the NTTR expansion comment site.

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